Payment reductions for drugs acquired through the 340B pricing program. The CMS proposes that these drugs be paid at average sales price (ASP) less 22.5 percent instead of the current ASP plus 6 percent. This dramatic cut would have a significant, negative impact on 340B hospitals that use the savings from the discounted drug pricing program to provide financial assistance to low-income patients who are unable to afford their prescriptions. Savings through the 340B program also helps these hospitals to improve access and provide more comprehensive services to vulnerable patients.

A reduction in the payment rate for services provided at nongrandfathered, off-campus, hospital outpatient departments. To comply with Section 603 of the Bipartisan Budget Act of 2015, the CMS established new rates under the Medicare physician fee schedule for payment of these services beginning in 2017. The payment currently equates to approximately 50 percent of OPPS rates. In 2018, the proposed payment would be equal to about 25 percent of the OPPS rate.

Removal of Total Knee Arthroplasty procedures from the inpatient-only list, since the association does not believe it is clinically appropriate for Medicare patients.

In the rule, the CMS proposes to remove six measures from the outpatient quality reporting program, with two measures proposed for removal in 2020 and four proposed for 2021 removal. The MHA supports the removal of these measures, but encourages the CMS to remove all six measures as soon as possible rather than staggering the process over a two-year period. In addition, the MHA urged the CMS to work with the hospital and community mental health center partial hospitalization program (PHP) providers to evaluate the variety of factors, beyond hours-per-week, that appropriately represent the “intensity” of services for a PHP. Other considerations could include factors such as the number of units of services provided per day and the types of services provided.